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City of Muskegon Heights, MichiganLocal Government

EIN: 386004639

UEI: GJM5M2C6X6G5

Audited by: Rehmann Robson LLC

Oversight agency: 21 [Department of the Treasury]

View federal awards & risk assessment →

Showing data from September 2, 2026 — the Federal Audit Clearinghouse is under high demand right now, so this couldn't be refreshed. This is the most recent data on record, not necessarily today's.

City of Muskegon Heights, Michigan4 audit years11 findings8 repeat
4
Audit Years
11
Total Findings
8
Repeat Findings
$5M
Federal Awards Expended (FY 2024)

FY 2024-12-31

$5,010,690 federal awards expended

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on September 25, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 25, 2026 (162 days ago).

What is a management decision? →
2024-004
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2023-005OTHER MATTERS

2024-004 – Procurement, Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A, DW-7640A, and DW-7686A. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the City. Such procedures are required whenever the amount disbursed to a single vendor in a given year is expected to be at least $25,000. Condition. The City did not verify that any of their vendors with purchases over $25,000 were not suspended or debarred from doing business with the City, or did not retain documentation to evidence that this verification had taken place. Cause. This condition was caused by management oversight in knowing the federal compliance requirements of the grant. Effect. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs have been questioned as a result of this finding, inasmuch as no suspended or debarred transactions were noted. Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred, and retain documentation to this verification. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

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Full finding narrative

2024-004 – Procurement, Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A, DW-7640A, and DW-7686A. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the City. Such procedures are required whenever the amount disbursed to a single vendor in a given year is expected to be at least $25,000. Condition. The City did not verify that any of their vendors with purchases over $25,000 were not suspended or debarred from doing business with the City, or did not retain documentation to evidence that this verification had taken place. Cause. This condition was caused by management oversight in knowing the federal compliance requirements of the grant. Effect. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs have been questioned as a result of this finding, inasmuch as no suspended or debarred transactions were noted. Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred, and retain documentation to this verification. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

Corrective Action Plan

2024-004 – Procurement, Suspension and Debarment (Repeat Finding) Auditor Description of Condition and Effect. The City did not verify that any of their vendors with purchases over $25,000 were not suspended or debarred from doing business with the City, or did not retain documentation to evidence that this verification had taken place. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Auditor Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred, and retain documentation to support this verification. Corrective Action. The City will maintain a schedule of dates checked for debarment. Responsible Person. Finance Director Anticipated Completion Date. December 31, 2025

Prior Finding References

2023-005

About Procurement and Suspension and Debarment →
2024-005
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2023-006OTHER MATTERS

2024-005 – Reporting (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A, DW-7640A, and DW-7686A. Criteria. The City is required to report the Coronavirus State and Local Fiscal Recovery Funds expenditures following applicable grant reporting guidance. Condition. While the City performed the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting for each quarter of 2024, the Project and Expenditure reports for the first three quarters of 2024 did not report any current period expenditures. Rather, the cumulative expenditures for the year were included in the fourth quarter Project and Expenditure report. In addition, the Project and Expenditure reports for the third and fourth quarters of 2024 were not filed within the required timeframe. Cause. This condition was caused by technical issues with the online grant reporting portal, and management not having processes in place to ensure that reports filed were accurate, complete, and filed timely. Effect. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted and the reports did not serve as a mechanism for reimbursement. Recommendation. We recommend that the City review the reporting requirements for each grant and complete all required reporting as required under the terms of the grant agreement. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

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Full finding narrative

2024-005 – Reporting (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A, DW-7640A, and DW-7686A. Criteria. The City is required to report the Coronavirus State and Local Fiscal Recovery Funds expenditures following applicable grant reporting guidance. Condition. While the City performed the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting for each quarter of 2024, the Project and Expenditure reports for the first three quarters of 2024 did not report any current period expenditures. Rather, the cumulative expenditures for the year were included in the fourth quarter Project and Expenditure report. In addition, the Project and Expenditure reports for the third and fourth quarters of 2024 were not filed within the required timeframe. Cause. This condition was caused by technical issues with the online grant reporting portal, and management not having processes in place to ensure that reports filed were accurate, complete, and filed timely. Effect. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted and the reports did not serve as a mechanism for reimbursement. Recommendation. We recommend that the City review the reporting requirements for each grant and complete all required reporting as required under the terms of the grant agreement. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

Corrective Action Plan

2024-005 – Reporting (Repeat Finding) Auditor Description of Condition and Effect. While the City performed the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting for each quarter of 2024, the Project and Expenditure reports for the first three quarters of 2024 did not report any current period expenditures. Rather, the cumulative expenditures for the year were included in the fourth quarter Project and Expenditure report. In addition, the Project and Expenditure reports for the third and fourth quarters of 2024 were not filed within the required timeframe. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Auditor Recommendation. We recommend that the City review the reporting requirements for each grant and complete all required reporting as required under the terms of the grant agreement. Corrective Action. City staff has accessed these reports and attempted to submit all required reports. Ongoing reports have been submitted on time. Assistance will be sought with federal agencies as necessary. Responsible Person. Finance Director Anticipated Completion Date. December 31, 2025

Prior Finding References

2023-006

About Reporting →
2024-006
Activities Allowed or Unallowed / Cost Allowability / Cash Management / Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2023-007OTHER MATTERS

2024-006 – Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management, and Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A, DW-7640A, and DW-7686A. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the City review and approve the draft policies as soon as practical. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

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Full finding narrative

2024-006 – Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management, and Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A, DW-7640A, and DW-7686A. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the City review and approve the draft policies as soon as practical. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

Corrective Action Plan

2024-006 – Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat Finding) Auditor Description of Condition and Effect. Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the City review and approve the draft policies as soon as practical. Corrective Action. City staff has reviewed drafts and will submit to City Council Uniform Grant Guidelines to be adopted. Responsible Person. Finance Director Anticipated Completion Date. December 31, 2025

Prior Finding References

2023-007

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Cash Management, Procurement and Suspension and Debarment →

FY 2023-12-31

$4,990,646 federal awards expended

FAC accepted this audit on August 28, 2024 — management decision was due February 28, 2025.

2023-005
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2022-006OTHER MATTERS

2023-005 – Procurement, Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A and DW-7640A. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the City. Such procedures are required whenever the amount disbursed to a single vendor in a given year is expected to be at least $25,000. Condition. The City did not verify that any of their vendors with purchases over $25,000 were not suspended or debarred from doing business with the City, or did not retain documentation to evidence that this verification had taken place. Cause. This condition was caused by management oversight in knowing the federal compliance requirements of the grant. Effect. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs have been questioned as a result of this finding, inasmuch as no suspended or debarred transactions were noted. Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred, and retain documentation to this verification. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

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Full finding narrative

2023-005 – Procurement, Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A and DW-7640A. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the City. Such procedures are required whenever the amount disbursed to a single vendor in a given year is expected to be at least $25,000. Condition. The City did not verify that any of their vendors with purchases over $25,000 were not suspended or debarred from doing business with the City, or did not retain documentation to evidence that this verification had taken place. Cause. This condition was caused by management oversight in knowing the federal compliance requirements of the grant. Effect. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs have been questioned as a result of this finding, inasmuch as no suspended or debarred transactions were noted. Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred, and retain documentation to this verification. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

Corrective Action Plan

2022-005 – Procurement, Suspension and Debarment (Repeat Finding) Auditor Description of Condition and Effect. The City did not verify that any of their vendors with purchases over $25,000 were not suspended or debarred from doing business with the City, or did not retain documentation to evidence that this verification had taken place. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Auditor Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred, and retain documentation to support this verification. Corrective Action. The City will maintain a schedule of dates checked for debarment. Responsible Person. Assistant Finance Director / Director of Planning and Community Development Anticipated Completion Date. December 31, 2024

Prior Finding References

2022-006

About Procurement and Suspension and Debarment →
2023-006
Reporting
SIGNIFICANT DEFICIENCYREPEAT OF 2022-007OTHER MATTERS

2023-006 – Reporting (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A and DW-7640A. Criteria. The City is required to report the Coronavirus State and Local Fiscal Recovery Funds expenditures following applicable grant reporting guidance. Condition. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports for first and second quarter of 2023 were not filed. However, these reports were filed for the third and fourth quarter of 2023. Cause. This condition was caused by technical issues with the online grant reporting portal, and management not having processes in place to ensure that reports filed were accurate, complete, and filed timely. Effect. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted and the reports did not serve as a mechanism for reimbursement. Recommendation. We recommend that the City review the reporting requirements for each grant and complete all required reporting as required under the terms of the grant agreement. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

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Full finding narrative

2023-006 – Reporting (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A and DW-7640A. Criteria. The City is required to report the Coronavirus State and Local Fiscal Recovery Funds expenditures following applicable grant reporting guidance. Condition. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports for first and second quarter of 2023 were not filed. However, these reports were filed for the third and fourth quarter of 2023. Cause. This condition was caused by technical issues with the online grant reporting portal, and management not having processes in place to ensure that reports filed were accurate, complete, and filed timely. Effect. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted and the reports did not serve as a mechanism for reimbursement. Recommendation. We recommend that the City review the reporting requirements for each grant and complete all required reporting as required under the terms of the grant agreement. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

Corrective Action Plan

2023-006 – Reporting (Repeat Finding) Auditor Description of Condition and Effect. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports for first and second quarter of 2023 were not filed. However, these reports were filed for the third and fourth quarter of 2023. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Auditor Recommendation. We recommend that the City review the reporting requirements for each grant and complete all required reporting as required under the terms of the grant agreement. Corrective Action. City staff has accessed these reports and attempted to submit all required reports. Ongoing reports have been submitted on time. Assistance will be sought with federal agencies as necessary. Responsible Person. City Manager Anticipated Completion Date. December 31, 2024

Prior Finding References

2022-007

About Reporting →
2023-007
Activities Allowed or Unallowed / Cost Allowability / Cash Management / Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2022-008OTHER MATTERS

2023-007 – Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management, and Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A and DW-7640A. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the City review and approve the draft policies as soon as practical. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

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Full finding narrative

2023-007 – Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management, and Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5, DW-7731A and DW-7640A. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the City review and approve the draft policies as soon as practical. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

Corrective Action Plan

2023-007 – Written Policies and Procedures Required by the Uniform Grant Guidance (Repeat Finding) Auditor Description of Condition and Effect. Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the City review and approve the draft policies as soon as practical. Corrective Action. City staff has reviewed drafts and will submit to City Council Uniform Grant Guidelines to be adopted. Responsible Person. City Manager Anticipated Completion Date. December 31, 2024

Prior Finding References

2022-008

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Cash Management, Procurement and Suspension and Debarment →

FY 2022-12-31

$5,042,434 federal awards expended

FAC accepted this audit on January 30, 2024 — management decision was due July 30, 2024.

2022-006
Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYREPEAT OF 2021-003OTHER MATTERS

2022-006 – Procurement, Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5 and SLFRP0127. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the City. Such procedures are required whenever the amount disbursed to a single vendor in a given year is expected to be at least $25,000. Condition. The City did not verify that any of their vendors over $25,000 were not suspended or debarred from doing business with the City. Cause. This condition was caused by management oversight in knowing the federal compliance requirements of the grant. Effect. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs have been questioned as a result of this finding, inasmuch as no suspended or debarred transactions were not suspended or debarred. Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

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Full finding narrative

2022-006 – Procurement, Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5 and SLFRP0127. Criteria. A recipient of federal awards is required to determine that vendors being paid with federal funds are not suspended or debarred from doing business with the City. Such procedures are required whenever the amount disbursed to a single vendor in a given year is expected to be at least $25,000. Condition. The City did not verify that any of their vendors over $25,000 were not suspended or debarred from doing business with the City. Cause. This condition was caused by management oversight in knowing the federal compliance requirements of the grant. Effect. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Questioned Costs. No costs have been questioned as a result of this finding, inasmuch as no suspended or debarred transactions were not suspended or debarred. Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

Corrective Action Plan

2022-006 – Procurement, Suspension and Debarment (Repeat Finding) Auditor Description of Condition and Effect. The City did not verify that any of their vendors over $25,000 were not suspended or debarred from doing business with the City. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Auditor Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred. Corrective Action. The City will maintain a schedule of dates checked for debarment. Responsible Person. Assistant Finance Director / Director of Planning and Community Development Anticipated Completion Date. June 30, 2024

Prior Finding References

2021-003

About Procurement and Suspension and Debarment →
2022-007
Reporting
MATERIAL WEAKNESSMODIFIED OPINIONREPEAT OF 2021-004

2022-007 – Reporting (Repeat Finding) Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5 and SLFRP0127. Criteria. The City is required to report the Coronavirus State and Local Fiscal Recovery Funds expenditures following applicable grant reporting guidance. Condition. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports have either not been submitted as required, or material errors were noted in the reports submitted. Cause. This condition was caused by technical issues with the online grant reporting portal, and management not having processes in place to ensure that reports filed were accurate, complete, and filed timely. Effect. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted and the reports did not serve as a mechanism for reimbursement. Recommendation. We recommend that the City contact the appliable federal agency to address technical issues with the online grant reporting portal and perform required reporting, making corrections as needed related to any previously filed reports in error. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

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2022-007 – Reporting (Repeat Finding) Finding Type. Material Noncompliance/Material Weakness in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5 and SLFRP0127. Criteria. The City is required to report the Coronavirus State and Local Fiscal Recovery Funds expenditures following applicable grant reporting guidance. Condition. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports have either not been submitted as required, or material errors were noted in the reports submitted. Cause. This condition was caused by technical issues with the online grant reporting portal, and management not having processes in place to ensure that reports filed were accurate, complete, and filed timely. Effect. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Questioned Costs. No costs are required to be questioned as a result of this finding, inasmuch as no unallowable expenditures were noted and the reports did not serve as a mechanism for reimbursement. Recommendation. We recommend that the City contact the appliable federal agency to address technical issues with the online grant reporting portal and perform required reporting, making corrections as needed related to any previously filed reports in error. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

Corrective Action Plan

2022-007 – Reporting (Repeat Finding) Auditor Description of Condition and Effect. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports have either not been submitted as required, or material errors were noted in the reports submitted. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Auditor Recommendation. We recommend that the City contact the appliable federal agency to address technical issues with the online grant reporting portal and perform required reporting, making corrections as needed related to any previously filed reports in error. Corrective Action. City staff has accessed these reports and attempted to submit all required reports. Ongoing reports have been submitted on time. Assistance will be sought with federal agencies as necessary.Responsible Person. City ManagerAnticipated Completion Date. June 30, 2024

Prior Finding References

2021-004

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2022-008
Activities Allowed or Unallowed / Cost Allowability / Cash Management / Procurement & Suspension/Debarment
SIGNIFICANT DEFICIENCYOTHER MATTERS

2022-008 – Written Policies and Procedures Required by the Uniform Grant Guidance Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management, and Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5 and SLFRP0127. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the City review and approve the draft policies as soon as practical. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

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2022-008 – Written Policies and Procedures Required by the Uniform Grant Guidance Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Allowable Costs/Cost Principles, Cash Management, and Procurement, Suspension and Debarment). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027; Award Numbers GJM5M2C6X6G5 and SLFRP0127. Criteria. The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and a conflict of interest policy) (§200.318); 3) Allowability of costs charged to federal programs (§200.302 (7)); 4) Compensation (personnel and benefits policy) (§200.430 and §200.431); and 5) Travel costs (including mileage and per diem) (§200.474). Condition. Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. Cause. This condition appears to be the result of a time lag in identifying the requirement and developing a plan for compliance. Effect. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing did not reveal any unallowed costs or excess cash draws. Recommendation. We recommend that the City review and approve the draft policies as soon as practical. View of Responsible Officials. The City agrees with the audit finding. A corrective action plan has been prepared.

Corrective Action Plan

2022-008 – Written Policies and Procedures Required by the Uniform Grant Guidance Auditor Description of Condition and Effect. Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants.Auditor Recommendation. We recommend that the City review and approve the draft policies as soon as practical. Corrective Action. City staff has reviewed drafts and will submit to City Council Uniform Grant Guidelines to be adopted. Responsible Person. City Manager Anticipated Completion Date. June 30, 2024

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FY 2021-12-31

MATERIAL NONCOMPLIANCE DISCLOSED$2,170,532 federal awards expended

FAC accepted this audit on November 28, 2023 — management decision was due May 28, 2024.

2021-003
Procurement & Suspension/Debarment
MATERIAL WEAKNESS

Condition and Criteria: The City is required to document vendor certification of suspension and debarment status on the SAM.gov website before applicable purchases. Cause: The City makes occasional purchases from vendors utilizing Federal funds. Context: Of the 13 transactions tested, one required consideratoin and dcumentation of suspension and debarment. Effect: The City made a federally funded purchase from a vendor without consideration of vendor suspension and debarment. This vendor is not suspended or debarred per review of the SAM.gov website. Recommendation: The City should develop policies and procedures to require documentation of vendor certification of suspension and debarment status before applicable purchases. Management Response: Management will develop policies and procedures to require documentation of vendor suspension and debarment status for all federally funded purchases or contracts.

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Condition and Criteria: The City is required to document vendor certification of suspension and debarment status on the SAM.gov website before applicable purchases. Cause: The City makes occasional purchases from vendors utilizing Federal funds. Context: Of the 13 transactions tested, one required consideratoin and dcumentation of suspension and debarment. Effect: The City made a federally funded purchase from a vendor without consideration of vendor suspension and debarment. This vendor is not suspended or debarred per review of the SAM.gov website. Recommendation: The City should develop policies and procedures to require documentation of vendor certification of suspension and debarment status before applicable purchases. Management Response: Management will develop policies and procedures to require documentation of vendor suspension and debarment status for all federally funded purchases or contracts.

Corrective Action Plan

The City of Muskegon Heights agrees with the finding identified and respectfully submits the following Corrective Action Plan for the year ending December 31, 2021. Management of the City is in the process of updating several policies within the City. Examples of the policies that will come out of this update will be a new procurement policy and a Federal grant management policy. The procurement policy will address suspension and debarment. Responsible party - City Manager.

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2021-004
Reporting
MATERIAL WEAKNESS

The City has been unable to perform the ARPA expenditure reporting following applicable grant reporting guidance due to technical issues with the online grant reporting portal. Context: The City was not able to complete the applicable ARPA expenditure grant reporting. Effect: The City has not completed the applicable ARPA expenditure grant reporting. Cause: The City has been unable to perform the ARPA expenditure reporting following applicable grant reporting guidance due to technical issues with the online grant reporting portal. Recommendation: The City should contact the appliable federal agency to address technical issues with the online grant reporting portal and perform required reporting. Views of responsible officials and planned corrective actions: The City agrees with this finding and management will contact the appliable federal agency to address technical issues and perform the required reporting.

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Criteria: The City is required to report the ARPA expenditures following applicable grant reporting guidance. Condition: The City has been unable to perform the ARPA expenditure reporting following applicable grant reporting guidance due to technical issues with the online grant reporting portal. Context: The City was not able to complete the applicable ARPA expenditure grant reporting. Effect: The City has not completed the applicable ARPA expenditure grant reporting. Cause: The City has been unable to perform the ARPA expenditure reporting following applicable grant reporting guidance due to technical issues with the online grant reporting portal. Recommendation: The City should contact the appliable federal agency to address technical issues with the online grant reporting portal and perform required reporting. Views of responsible officials and planned corrective actions: The City agrees with this finding and management will contact the appliable federal agency to address technical issues and perform the required reporting.

Corrective Action Plan

We concur with the assessment regarding reporting of the ARPA funds. The City continues to work with the Federal government to resolve reporting issues that are occuring with the initial submission. The expectation will be that the Federal reposting will be completed as soon as possible, and all future reposrts be submitted in a timely fashion. Responsible party: City Manager

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